MEYER v. STATE OF NEW JERSEY
2:21-cv-15273
| D.N.J. | Jun 30, 2025Background
- Robert John Meyer, a civilly committed individual at New Jersey's Special Treatment Unit (STU), filed a civil rights complaint under 42 U.S.C. § 1983 and state law, alleging misconduct stemming from a 2014 incident with corrections officers following a verbal altercation.
- Meyer was criminally charged based on allegedly false reports by STU officials, convicted of some charges at trial, and later had his conviction reversed by the Appellate Division in 2018.
- The charges against Meyer were formally dismissed by the state court with prejudice in July 2019.
- Meyer filed his original federal complaint in August 2021, more than two years after the charges were dismissed.
- He argued that COVID-19 lockdowns, law library closures, and confusion about tort claim requirements delayed his filing.
- The District Court screened the Amended Complaint under 28 U.S.C. § 1915(e)(2)(B), considering timeliness and equitable tolling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| § 1983 claims time-barred | Filing was delayed due to COVID-19 and belief tort claim notice response was needed | Claims facially outside NJ's 2-year personal injury statute of limitations | Dismissed as untimely |
| Equitable tolling due to COVID-19 | Lockdowns and law library access prevented timely filing | Plaintiff had time pre-pandemic; COVID restrictions insufficient for tolling | No equitable tolling granted |
| Equitable tolling for wrong forum filing | Timely filed notice of claim with state prior to the deadline | State tort notice isn't equivalent to complaint in wrong forum | Notice of claim does not toll § 1983 limitations |
| Supplemental jurisdiction over state law | Federal claims dismissed but state claims remain | N/A | No supplemental jurisdiction—may file in state court within 30 days |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (standard for facial plausibility at pleadings)
- Thompson v. Clark, 596 U.S. 36 (favorable termination accrual rule for malicious prosecution)
- McDonough v. Smith, 588 U.S. 109 (limitations period for fabricated-evidence claims begins at favorable termination)
- Dique v. N.J. State Police, 603 F.3d 181 (state personal injury law dictates § 1983 limitations period)
- Gallo v. City of Phila., 161 F.3d 217 (malicious prosecution under § 1983 may be based on false evidence by non-prosecutors)
- Doe v. Delie, 257 F.3d 309 (constitutional right to medical privacy for inmates)
- A.M. ex rel. J.M.K. v. Luzerne Cnty. Juvenile Detention Ctr., 372 F.3d 572 (supervisor liability standard under § 1983)